MEMORANDUM AND ORDER
OLIVER, District Judge.
Pending before the court is a motion filed by Defendant, United States of America, to dismiss Plaintiff's Complaint for lack of subject matter jurisdiction. The Defendant argues Plaintiff did not comply with the statutory prerequisites for bringing a refund suit. For the reasons that follow, the motion is granted in favor of the United States.
I.
On November 2, 1994, the Plaintiff filed...
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